VOSH PROGRAM DIRECTIVE: 14-222B ISSUED: March 1, 2005

SUBJECT: Local Emphasis Program: Lumber and Wood Products, SIC Group 24 Lynchburg,
Roanoke, Abingdon and Verona Offices Only

A. Purpose

This directive provides revised procedures to be followed for this general industry local emphasis
program (LEP) and transmits this LEP to field personnel. This directive also cancels VOSH Program
Directive 14-212D, the Local Emphasis Program for “Operation Lifesaver” in the Logging Industry.

This Program Directive is an internal guideline, not a statutory or regulatory rule, and is intended to
provide instructions to VOSH Personnel regarding internal operation of the Virginia Occupational
Safety and Health Program and is solely for the benefit of the Program. This document is not subject to
the Virginia Register Act or the Administrative Process Act; it does not have general application and is
not being enforced as having the force of law.

B. Scope

This Directive is limited in scope and only applies to VOSH personnel in the Lynchburg, Roanoke,
Abingdon and Verona offices.

C. Reference

Not Applicable.

D. Cancellation

VOSH Program Directive 14-212D (April 1, 2003)

E. Action

Directors and Managers shall ensure that procedures established in this Directive are adhered to in
conducting inspections involving this local emphasis program.

F. Effective Date

March 1, 2005
G. Expiration Date

Not Applicable.

H. Background

Because of the continuing incidence of SIC Group 24 injuries and fatalities in Virginia in the areas
covered by the Lynchburg, Roanoke, Abingdon and Verona offices, VOSH has determined that a special
emphasis program effort only for these offices is warranted. The emphasis program will require
increased VOSH presence to inform general industry operations of the hazardous conditions existing on
their worksites.

I. Summary

This LEP will focus on all of SIC Group 24 including:

241 Logging
242 Sawmills and Planing Mills
243 Millwork, Veneer, Plywood and Structural Wood Members
244 Wood Containers
245 Wood Buildings and Mobile Homes
249 Miscellaneous Wood Products

Added emphasis will be placed on inspections of companies with 100 or fewer employees as nearly 80
percent of fatalities occurred in companies with less than 100 employees.

J. Procedures

The VOSH Director shall ensure that the Northern Virginia and the Southwest Regional Directors
develop a general industry list to include establishments covered by this LEP.

1. All compliance personnel shall be instructed to be on the lookout for SIC Group 24 activities.
Every observation of these activities shall be handled as follows:

a. Regardless of whether a violation is observed, whenever a CSHO sights or receives any

other notice of a related general industry or construction operation, including other
government referrals and reports from members of the public), the CSHO shall:

(1) Make note of the state and condition of the work operation insofar as it is known,
including any apparent serious hazards.

(2) Note the name and address or location of the worksite and the contractor (where
applicable) performing the operation, if known.

b. All work activities shall be inspected. The CSHO shall immediately notify his supervisor
that an inspection has been opened pursuant to this LEP.

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 c. Complaints and other referrals involving general industry and construction operations
where violative activities are occurring shall be scheduled as unprogrammed inspections
under the LEP conducted in accordance with procedures found in the VOSH FOM. Such
notices, therefore, need not be responded to with the usual letter to the employer.

2. Although sightings will normally be those which occur during the course of routine travel during
duty or nonduty hours, the discovery of these work activities may be the result of a specific
search to find related activities at the discretion of the Commissioner. Verification of
information received from sources other than CSHO observation, as indicated in J.1.a. of this
directive, is also permitted under this LEP.

3. Documentation of the events leading up to the observation or the reporting of applicable

activities shall be maintained by the Regional Office in case of denial of entry.

4. When an inspection is not conducted because of denial of entry, a warrant shall be sought in
accordance with the current procedures for handling such cases. A warrant may not be
necessary, however, if the violations are in plain view. In such situations, the Regional
Compliance Manager shall contact the Office of Legal Support for guidance.

5. The scope of inspections conducted under this LEP shall normally be limited to SIC Group 24
activities. If the inspection is to be expanded, the principles given in the VOSH FOM shall be
followed.

K. Scheduling Inspections

The following guidelines shall be adhered to in scheduling inspections:

(1) All establishments on the "Lumber and Wood Products" list shall be inspected except those
establishments deleted from the list, pursuant to the FOM. There will be no exemption for
employers with 10 or fewer employees.

(2) Establishments selected for inspection may be scheduled in any order that makes efficient use of
available resources.

(3) When an inspection is not conducted because the employer has refused entry, a warrant shall be
sought in accordance with the current procedure for handling such refusals.

(4) Inspections conducted under this LEP normally shall be comprehensive.

L. Recording in IMIS

The following guidelines shall be followed when recording inspections conducted under this LEP .

1. For IMIS purposes, the VAOSH-1 will be completed as follows:

For Inspection Type, find item 24, and enter an “H” after the colon. (This will yield
“Programmed Planned” on the screen.)

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 For Inspection Classification, find item 25c and enter a “Y” after the colon. (This will yield
“Local Emphasis Program” on the pop-up box. Enter “SAWMILLS “ in all caps in
the left-hand column of the pop-up box.

2. No Inspection Conducted: When no inspection is conducted, the VAOSH-1 form shall be

marked “No inspection” (Item 35, marked “D” after the colon; “Close” (Item 44, marked “A”);
“No Citations Issued: (Item 44, marked “B”); and “Other” (Item 45, marked “I.”). Record
“SAWMILLS” in the space 45I. “Opening Conference date” (Item 20) which will be the date of
entry (enter the date–month/day/year) and “Closing Conference Date” (On Site) (Item 46) will
be the date of exit (enter the date - month/day/year). Opening and closing dates are the same
date when no inspection is conducted.

Note: If you have any questions regarding the proper way to record in IMIS, please contact the VOSH
IMIS section.

C. Ray Davenport
Commissioner

Attachment: None

Distribution: Commissioner of Labor and Industry

Assistant Commissioner – Programs
Directors and Managers
VOSH Compliance Staff
Cooperative Programs Staff
Legal Support Staff
OSHA Regional Administrator, Region III
OSHA Area Office, Norfolk